AI-washing – when AI hype becomes a litigation risk
The Government's new Fraud Strategy starts from a stark premise: fraud remains the largest volume crime affecting individuals and businesses in the UK, with an estimated economic and social cost of at least £14.4 billion in 2023-2024. The strategy's central policy claim is therefore an important one – reducing fraud is not only a crime objective, but an economic one. Every pound lost to fraud is a pound not reinvested in the economy.
Early reaction has also been broadly supportive. Public comments issued alongside the launch welcomed the strategy from across policing, the FCA, major telecoms providers, banks and large technology businesses. That does not guarantee delivery, but it does suggest the Government has landed on a model that key operational partners regard as credible.
The strategy is built around three pillars – “Disrupt”, “Safeguard” and “Respond” – but its centre of gravity is plainly the first of those. The most eye-catching measure is the new Online Crime Centre, backed by £31 million and intended to bring together the Home Office, the NCA, City of London Police, intelligence partners and private-sector participants from financial services, telecoms, technology and cyber. On paper, this looks less like a rival enforcement body and more like a permanent intelligence and disruption hub: a mechanism for turning fragmented data into faster interventions against accounts, websites, numbers and other infrastructure used by fraud networks.
This public-private model does not come from nowhere. The strategy reads as the culmination of a trend that has been building for some time. The Stop! Think Fraud campaign launched in February 2024 was already framed around coordinated messaging backed by government, law enforcement and industry. The 2023 Online Fraud Charter and the second Telecommunications Fraud Charter published in November 2025 pointed in the same direction, with increasing emphasis on shared standards, intelligence sharing, network interventions and joint prevention activity. The recent NCA-NatWest campaign on invoice fraud is another example of this expanding public-private partnership.
Set against that background, some of the key proposals in the strategy are:
The Online Crime Centre promises to be more than just a gimmick. The strategy is clear that one of the core problems is a fractured data landscape in which different actors hold useful intelligence, but no one sees the whole picture in real time. The OCC is designed to address exactly that. It also sits alongside a new call for evidence on economic crime information sharing, which suggests the Government knows that legal and operational barriers to sharing data remain one of the main constraints on effective disruption.
The private-sector angle is especially important. Financial institutions have long played a central role in the counter-fraud system, but the strategy recognises more clearly than some earlier initiatives that telecoms and tech firms are also critical control points. That is sensible. In much online fraud, the decisive intervention may happen long before any bank transfer – in the blocking of a spoofed number, the removal of a malicious advert, the suppression of a fraudulent listing, or the disruption of infrastructure at source. In that respect, the strategy’s emphasis on upstream disruption feels more realistic than an enforcement model built mainly around downstream investigations.
The international dimension is also one of the stronger features of the document. The strategy accepts that a large share of serious fraud is overseas and points to operational cooperation with countries including Nigeria and Vietnam. That is not an admission of defeat for UK law enforcement. In many cases, prosecution and disruption in the jurisdiction where the fraud factory actually sits will be the more practical and effective route. If local partners can raid the site, seize devices, arrest suspects and dismantle infrastructure, that may be a better outcome than treating extradition to the UK as the default.
The recent Agbor case in Nigeria, in which the NCA, Meta and the Nigerian Police Force supported action against an alleged scam centre targeting victims in the UK and the US, helps to show how this model can work in practice. Operation Serengeti illustrates the same logic on a broader scale: a multinational disruption effort spanning the UK and 18 African countries, aimed at dismantling cyber-enabled fraud networks and the infrastructure they rely on. Both examples are useful because they show that, where fraud operations are based overseas, the most effective result may often come from supporting enforcement action in the jurisdiction where the suspects, devices and operational infrastructure are actually located.
None of that means the strategy is beyond criticism. The “Safeguard” pillar is comparatively light on operational detail, leaning heavily on education, reducing vulnerability to fraud and existing protective networks. The “Respond” pillar is also thinner than the disruption agenda, with some of its justice content relying on reviews, pilots, evaluations and already signalled reforms. Businesses may also note that the strategy is firmer on the possibility of future regulation than on immediate hard obligations. On online advertising in particular, the Government has reserved the right to legislate if partnership and market incentives do not produce meaningful improvement.
Still, the fact that the strategy is not trying to do everything through criminal prosecutions is arguably a strength rather than a weakness. Fraud at this scale cannot be solved by enforcement alone. A system that is better at sharing intelligence, closing vulnerabilities, measuring sector performance and intervening earlier is likely to be more effective than one that continues to rely too heavily on victim reporting and reactive case-building.
Overall, this is a serious strategy. Some will argue that £250 million over three years is still modest against the scale of the problem, and that is a fair point. But it would be wrong to dismiss the document as thin or superficial. It is detailed, it reflects extensive stakeholder engagement, and it shows a more mature understanding of fraud as a transnational, technology-enabled threat that requires shared operational ownership across government, law enforcement and industry. The real test will be whether the Online Crime Centre and the other proposals in the strategy can translate into measurable disruption. If they can, this strategy may come to be seen as the point at which the UK’s counter-fraud model became materially more effective.
Authored by Reuben Vandercruyssen and Melody Stephen.